Karen Ann Keegan - Page 7

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            deductions claimed.  INDOPCO, Inc. v. Commissioner, 503 U.S. 79,                          
            84 (1992).                                                                                
            1.  Respondent's Reconstruction of Petitioner's Income                                    
                  Pursuant to a reconstruction of petitioner's income for the                         
            taxable year 1994, respondent determined that petitioner had                              
            failed to report gross income in the amount of $4,578.                                    
                  Taxpayers are required to maintain adequate records of                              
            taxable income.  Sec. 6001.  Where a taxpayer fails to produce or                         
            maintain adequate records from which actual income may be                                 
            ascertained, the Commissioner may reconstruct a taxpayer's income                         
            by any method that clearly reflects income.  Sec. 446(b); Goodmon                         
            v. Commissioner, 761 F.2d 1522, 1524 (11th Cir. 1985); Petzoldt                           
            v. Commissioner, 92 T.C. 661, 687, 693 (1989).  The method of                             
            reconstructing income need only be reasonable in light of all                             
            surrounding circumstances.  Petzoldt v. Commissioner, supra at                            
            687.                                                                                      
                  The source and application of funds method has been regarded                        
            as a reasonable method of determining income.  United States v.                           
            Johnson, 319 U.S. 503, 517-518 (1943); Meier v. Commissioner, 91                          
            T.C. 273, 295-296 (1988).  As explained by this Court in DeVenney                         
            v. Commissioner, 85 T.C. 927, 930 (1985):                                                 
                        The * * * [source and application of funds] method                            
                  is based upon the assumption that the amount by which a                             
                  taxpayer's cash expenditures during a taxable period                                
                  exceed * * * [the taxpayer's] known sources of income                               
                  for that period is taxable income, unless the taxpayer                              





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